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This will make sure that they are treated in the same way as excluded property for the purposes of restricting the deduction of a liability.

This will close a loophole that would otherwise allow the new rules to be sidestepped and a deduction for a liability to be allowed where the borrowed funds are deposited in a foreign currency account in a UK bank which is disregarded for Inheritance Tax purposes. The measure supports the government’s anti-avoidance strategy and fairness agenda.